{"operation":"document","citation":"CPF 12026025NOA","title":"CENTRAL VALLEY GAS STORAGE (CVGS), LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2026-02-13","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12026025noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12026025NOA","body":"Notice of Amendment involving CENTRAL VALLEY GAS STORAGE (CVGS), LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2026-02-13 and is reported as closed as of 2026-04-29. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12026025NOA_Closure Letter_04292026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Closure%20Letter_04292026_(25-340130).pdf\n\n12026025NOA_Closure Letter_04292026_(25-340130)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Closure%20Letter_04292026_(25-340130)_text.pdf\n\n12026025NOA_Notice of Amendment_02132026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Notice%20of%20Amendment_02132026_(25-340130).pdf\n\n12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Notice%20of%20Amendment_02132026_(25-340130)_text.pdf\n\n12026025NOA_Operator Response to Notice_03122026_(25-340130).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12026025NOA/12026025NOA_Operator%20Response%20to%20Notice_03122026_(25-340130).pdf\n\n12026025NOA_Notice of Amendment_02132026_(25-340130)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, NJ 08628\n609.771.7800\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: drm@calichestorage.com\nFebruary 13, 2026\nDave Marchese\nChief Executive Officer\nCaliche Development Partners, LLC\n919 Milam Street, Suite 2425\nHouston, TX 77002\nCPF 1-2026-025-NOA\nDear Mr. Marchese:\nFrom March 10 to 21, 2025, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.), conducted\nan inspection of Central Valley Gas Storage LLC’s (CVGS) procedures in Colusa County,\nCalifornia.\nAs a result of the inspection, PHMSA has identified an apparent inadequacy found within the\nCVGS’s plans or procedures. The alleged inadequacy and proposed revision is described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\n\n\n\nCPF 1-2026-025-NOA\nCVGS’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility in accordance\nwith section 192.12(c). Specifically, CVGS’s Integrity and Risk Management Plan (12/30/24)\n(I&R Plan) failed to include a requirement to review and update its operations and maintenance\nprocedures (manuals) at intervals not exceeding 15 months, but at least once each calendar year,\nin accordance with section 192.12(c).\nDuring the inspection, PHMSA reviewed the CVGS I&R Plan and determined that the procedures\nfailed to include requirements that CVGS operations and maintenance procedures be reviewed and\nupdated at intervals not exceeding 15 months, but at least once each calendar year, they instead\nrequired annual reviews in section 5.1.2.\nTherefore, CVGS’s written procedures for conducting operations, maintenance, and emergency\npreparedness and response activities were inadequate to ensure safe operation of a pipeline facility\nin accordance with section 192.12(c). PHMSA proposes that CVGS revise its procedures to\naddress the inadequacy noted above.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 CFR § 190.206. Enclosed as part\nof this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you submit\nin response to this enforcement action is subject to being made publicly available. If you believe\nthat any portion of your responsive material qualifies for confidential treatment under 5 U.S.C. §\n552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. § 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under 49 CFR § 190.211. If you do not respond within 30\ndays of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in\nthis Notice and authorizes the Associate Administrator for Pipeline Safety to find facts as alleged\nin this Notice without further notice to you and to issue an Order Directing Amendment. If your\nplans or procedures are found inadequate as alleged in this Notice, you may be ordered to amend\nyour plans or procedures to correct the inadequacies (49 CFR § 190.206). If you are not contesting\nthis Notice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Central Valley Gas Storage LLC maintain documentation of\nthe safety improvement costs associated with fulfilling this Notice of Amendment\n(preparation/revision of plans, procedures) and submit the total to the Director, Eastern Region,\nPipeline and Hazardous Materials Safety Administration, Office of Pipeline Safety. In\nPage 2 of 3\n\n\n\nCPF 1-2026-025-NOA\ncorrespondence concerning this matter, please refer to CPF 1-2026-025-NOA and, for each\ndocument you submit, please provide a copy in electronic format whenever possible.\nSincerely,\nRobert Burrough\nDirector, Eastern Region, Office of Pipeline Safety\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\nPage 3 of 3\n\n12026025NOA_Closure Letter_04292026_(25-340130)_text.pdf\n\nU.S. Department\nof Transportation\nPipeline and\nHazardous Materials\nSafety Administration\n840 Bear Tavern Road, Suite 300\nWest Trenton, New Jersey 08628\n609.771.7800\nVIA ELECTRONIC MAIL TO: drm@calichestorage.com\nApril 29, 2026\nDave Marchese\nChief Executive Officer\nCaliche Development Partners, LLC\n919 Milam Street, Suite 2425\nHouston, TX 77002\nRE: CPF 1-2026-025-NOA\nDear Mr. Marchese:\nFrom March 10 to 21, 2025, a representative of the Pipeline and Hazardous Materials Safety\nAdministration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.) conducted\nan inspection of Central Valley Gas Storage LLC’s (CVGS) procedures in Colusa County,\nCalifornia. As a result of the inspection, PHMSA identified an apparent inadequacy found within\nCVGS’s plans or procedures.\nCVGS submitted its amended procedures on March 12, 2026. My staff reviewed the amended\nprocedures, and it appears that the inadequacies outlined in this Notice of Amendment have been\ncorrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\ncc: Afton Sterling, Vice President of Regulatory, Environmental, Health & Safety,\nasterling@calichestorage.com","truncated":false,"body_characters":8103}